In the case of Work, Secretary of the Interior, Johnson, Governor of the Chickasaw Nation et al. v. United States ex rel. McAlester-Edwards Company (1922), the Supreme Court ruled on a dispute over coal and asphalt deposits in lands belonging to Choctaw and Chickasaw Nations in Oklahoma. The McAlester-Edwards Company had leased these lands for mining purposes but was later denied by federal officials who claimed that such leases were invalid without Congressional approval under an 1898 law governing tribal land use rights. The company sued for damages arguing that they had been unlawfully deprived of their leasehold interests. The court held that while Congress did have authority over tribal affairs, it could not unilaterally abrogate contracts made between tribes and third parties without providing compensation as this would constitute a taking under Fifth Amendment protections against uncompensated takings by government entities. Thus, although Congress could regulate or even prohibit certain types of economic activity on Indian reservations including mineral extraction activities like those at issue here; any such regulatory actions must respect existing contractual obligations unless just compensation is provided to affected parties thereby upholding principles central to American contract law and constitutional property rights jurisprudence.

In the dissenting opinion for Work, Secretary of the Interior, Johnson, Governor of the Chickasaw Nation v. United States ex rel. McAlester-Edwards Company (1922), Justice Holmes argued that Congress had not intended to give coal and asphalt deposits in Indian lands to private companies without compensation or a bidding process. He believed that such an interpretation would be contrary to public policy and common sense as it would amount to giving away valuable public resources for free. Instead, he contended that Congress meant only to allow these companies access rights under certain conditions and with appropriate payment made towards those who held title over these lands - namely, Native American tribes like the Chickasaw Nation.